COMMUNITY HOSPITALS AND WELLNESS CENTERS
PROTECTED HEALTH INFORMATION PRIVACY NOTICE
(Effective April 14, 2003)

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  PLEASE READ THIS NOTICE CAREFULLY.

          A Federal Privacy Law (known as the Health Insurance Portability and Accountability Act) was passed by Congress to further increase the information safeguards and security of patient healthcare data.

          Patient Health Information (PHI), is identifiable health information that has been collected from an individual by a healthcare provider as it relates to the past, present, or future physical or mental health or condition of the individual.  Health information that does not identify a patient is not (PHI).  Access to (PHI) will be provided on a need-to-know basis.  In other words, staff members and business associates are given access to (PHI) only when there is a legitimate clinical and/or business need for the information.  In addition, staff and business associates can not attempt to access (PHI) unless they have been granted appropriate access rights and have a clear business reason to do so.  Policies and procedures have also been implemented and technological tools that restrict access and use of (PHI) based on the specific roles of its workforce (including employees, contractor, physicians, volunteers, temporary workers, and business associates) have also been employed.  All non-routine requests are reviewed on an individual basis to determine whether the (PHI) requested is the “minimum necessary” and is responded to, appropriately.

          Patient consent is obtained in writing during registration, permitting usage or disclosing (PHI) to carry out treatment, payment, or healthcare operations.  Other uses/disclosures will be made only with the patient’s written authorization and the patient may revoke such authorization.  (PHI) may be used/disclosed without prior written authorization, when:  (1) There is an indirect treatment relationship.  (2) Emergency treatment situations (unable to obtain prior consent, and consent will be attempted as soon as is reasonably practicable after the delivery of such treatment).  (3) When required by law to treat a patient (attempted to obtain consent but unable to do so).  (4) Attempted to obtain consent but was unable to do so, due to substantial barriers in communication, and it is determined that the patient’s consent to receive treatment is clearly inferred from the circumstances.  Attempts to obtain consent and the reasons why consent was not obtained will be documented.  Consent obtained by another provider will not be utilized unless there was an indirect treatment relationship with the patient, or there is a reliance upon a joint consent.  Furthermore, patients have the right to receive confidential communications and to inspect, copy, amend, receive accounting of (PHI) disclosures, and to obtain in a paper copy of the (PHI) notice, upon request.

          If you believe a violation has occurred, you should contact the facility Privacy Officer at 636-1131 (extension 1142) or address your complaint to the Chief Executive Officer; 433 W. High Street; Bryan, Ohio 43506.  You may also file a complaint with the Office of the Secretary; Dept. of Health & Human Services; 200 Independence Ave. SW; Washington, D.C.  20201; or (http://www.hhs.gov).